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lambda-cyhalothrin (Karate, Force) Registration Approval 9/93

Mr. Michael S. O'Conner                      SEP 20, 1993
ZENECA, Incorporated
Western Research Center
1200 S. 47th Street
Box 4023
Richmond, California  94804-0023

Dear Mr. O'Conner:

Re:  Reqistration of Force 1.5G Insecticide EPA Reg. No. 10182-130

The New York State Department of Environmental Conservation has approved your 
application to register the referenced pesticide product, containing the new 
active ingredient tefluthrin.  Force l.5G Insecticide is a granular soil-
applied product used to control insects on field corn, popcorn, and seedcorn.

This Department reviewed all of the information submitted in support of the 
registration, along with the continuously evolving mitigation measures, and 
has determined that use of the referenced product in conformance with the 
label directions is not likely to result in significant health or 
environmental risks.  Documentation provided to the Department for review 
indicates that the fish kills associated with Force l.5G Insecticide were due 
to use of the product in a manner not in conformance with the label.  The 
recent label amendments place greater emphasis on the need to incorporate the 
product into soil at the time of application.  In addition, the change in 
formulation reduces the potential for runoff of the active ingredient.  No 
fish kill incidents have been associated with use of the alternate 
formulations (WFl535).

Since Force l.5G is a federally restricted use pesticide, the same 
classification must apply in New York State.  Please note that New York State 
Environmentai Conservation Law (ECL) 33-09Ol.l states that:  "A commercial 
permit is required for the distribution, sale, offer for sale, purchase for 
the purpose of resale or possession for the purpose of resale of a restricted 
use pesticide."  Thus, if ZENECA, Inc., proposes to sell or offer for sale any 
restricted use pesticide to any person within New York State, a commercial 
permit is required.  ECL 33-0905.l further states that:  "Any person who 
engages in...the sale of restricted use pesticides shall be certified by the 
Commissioner..."  Therefore, commercial permit holders must employ or retain 
under contract at least one person who is certified in New York State for the 
application of restricted use pesticides.

Enclosed is information pertaining to commercial permits in New York State, 
along with an application form for your convenience.  Questions regarding 
commercial permits and certification should be directed to our Bureau of 
Pesticide Regulation at (518) 457-7482.

On June 14, 1993, in accordance with FIFRA Section 3(c)(7)(c), the United 
States Environmental Protection Agency (USEPA) extended the conditional 
registration of the referenced product for a period not to exceed November 15, 
1994 and imposed the following conditions:

"(a)  By November 31, 1993 ZENECA will submit to the Agency an initial 
proposal to address EPA's risk concerns which will consist of proposed aquatic 
risk reduction measures.

"(b)  After receipt of the proposal, the Agency will evaluate the proposed 
risk reduction measures and if necessary meet to determine if it meets the 
Agency's expectations regarding adequate mitigation measures.

"(c) Make Agency's scientists available to discuss the proposed risk reduction 
measures as it progresses with the goal of achieving agreement on a final 
course of action by November 15, 1994."

As specified above in the terms of the conditional registration extension, the 
USEPA requires the development of additional aquatic risk reduction measures. 
As a condition of registration in New York State, ZENECA, Inc., must provide 
this Department with copies of correspondence and studies related to any 
proposed amendment of the federal registration status of the referenced 
product simultaneous with their submission to the USEPA.  Documentation 
detailing the final USEPA registration decision must also be submitted to this 
Department within 30 days of receipt by ZENECA, Inc.

The Department recognizes the crucial role of soil incorporation of the 
subject product.  If customary use of Force 1.5G Insecticide results in fish 
kills, the Department will reexamine this product and determine whether any 
further regulatory steps are appropriate.

The approved label is the federally registered label as submitted.  Also 
enclosed, for your records, is the Certificate of Pesticide Registration and a 
copy of the stamped-accepted label.

Sincerely,



Norman H. Nosenchuck, P.E.
Director
Division of Hazardous Substances Regulation

Enclosures

cc:  w/encs. - Donald Rutz, Cornell University
             - James Tette, Cornell University
             - Dennis Rapp, N.Y.S. Dept. of Ag. and Mkts.